11 September, 2023
Working Group Update 9/11/2023
11 September, 2023
- FIF Rule 606 Working Group. The Rule 606 Working Group continued the review and discussion of the SEC’s recent approval of the FINRA rule filing to require Rule 606(a)-type reporting for OTC equities. The Working Group discussed issues and questions from FIF members relating to the new rule. The Working Group reviewed and made final edits to a draft FIF member letter to FINRA with comments and questions relating to the new rule. FIF submitted the letter to FINRA on September 7.
- FIF CAT Monthly Update Working Group Call. The Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT Transaction Reporting and CAT CAIS reporting during the prior month. The Working Group also reviewed the current areas of focus for FIF members and the current open issues for CAT Transaction Reporting and CAT CAIS reporting.
- FIF CAT Transaction Reporting Working Group. FIF hosted two calls this week for the CAT Transaction Reporting Working Group. During the first call, the Working Group reviewed and edited draft letters to the CAT Plan Participants, FINRA CAT and the SEC on CAT reporting for non-executable RFQ responses. FIF submitted these letters on September 6. During the second call, the Working Group discussed the SEC’s recent approval of the Executed Share Model for CAT funding. The Working Group also discussed issues and questions from FIF members on reporting the ATT handlingInstructions value for market maker PEG orders, the CAT system generating an error when a firm executes a customer DAY order after trade date to resolve a trading error, the current status of the SEC’s proposal to require CAT reporting of a buy-to-cover order marker, and the current status of the SEC’s proposal to require a market maker to report to CAT when the market maker relies on the bona fide market maker exception from the locate requirement.
Eduard Kotlyar